McKeel Comments 3/28/12 TBD-6000 work group meeting

6.

No new Old Betatron model was introduced by NIOSH and Mr. Allen in
either recent white paper for the Path Forward GSI initiative.

(a) This facility was built 10 years earlier than the New Betatron
building by a different contractor using different materials

(b) The New Betatron building was a short distance away froma
heavily populated work area in building 10; the Old Betatron was located
in a field 300 feet away from the New Betatron facility.

(c) The Old Betatron building had different physical characteristics
that are not completely defined. Engineering drawings do not exist for
either Betatron facility—only sketches that are not to scale and are not
accompanied by any certified list of construction materials.

Most importantly

(d) Alll of the MCW AEC contracted uranium NDT work between
4953 and 1963, including the peak production year of 1962, was done in
the Old Betatron facility. The New Betatron building was not built until
1963.

(e) This is also an SEC issue: Based on Path Forward progress to
date after 18 months, NIOSH has not been able to develop and validate

an updated Old Betatron exposure model using the production code of
MCNPx together with real world, measured data.

NIOSH has not modeled the two GSI radium-226 sources correctly.
The sources were used inside the 6 building Radiography facility pre-1962
as well as in other GSI buildings as testified to by workers. Petitioners
have shown at the 3/15/12 work group meeting that “Radiograph Room”
bldg. 6 facility existed as indicated on a January 29, 1957 GSI plant
engineering drawing. This is also an SEC issue.

The GSI owned Iridium-192 NDT source was not modeled at all in the
Path Forward white papers. In the 3/15 meeting Petitioners reviewed 5

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McKeel Comments 3/28/12 TBD-6000 work group meeting

the Betatron output) and GSI work force measured data from 1971 outside
the covered period. (see item #3)

3. Petitioner objects to NIOSH and SC&A passing off Betatron residual
radiation, that was measured, as “magnetic interference” (their
unproven construct), by a paid CDC/NIOSH consultant. In fact, because
set up workers were exposed at a distance of 1 to 2 feet rather than 6 feet
from the Betatron nose cone, while the machine power was turned off, the
inverse square lay indicates a dose of 60 mR rather than 5 mR should be
assigned. NIOSH has ignored more recent testimony, replicated in the
McKeel post 3/15/12 white papers, that they measured residual radiation
emanating from the donut tube within seconds after removing it from an
Allis-Chalmers Betatron from the same period as the GSI Betatrons.

4. SC&A in 2008 modeled an 80 Curie source at GSI. Dr.. recently
pointed out correctly that the Allen Co-60 model assumed the source was
80 Curie when in actuality it was 54 Curies in 1971. This nuance was not
factored into the 2008 model of the same GSI source term.

Path Forward documents have stated GSI obtained the 80 Curie
GSI source after 1966, a point that at least 6 GSI workers dispute,
testifying the large source was present during the 1964-66 time period.
Petitioner believes NIOSH should model the Co-60 80 Curie source to
comply with OCAS-IG-003 guidance.

This is an SEC Issue because the NIOSH Path Forward white
papers have not modeled this very important source term.

5. No direct, measured monitoring data exists for either operating
Betatron for any portion of the covered 1953-1966 time period. This
includes air monitoring or neutron flux, plausible coworker data or
surrogate data. There are no valid computer models for this because there
is no real data to validate the models. MCNPx alone is not sufficient.

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McKeel Comments 3/28/12 TBD-6000 work group meeting

10.

pieces of evidence that such a source was used (to inspect pipe welds in
buildings 9 and 19 and rail/transit car trucks in the 6 Bldg. radiography
facility, the way it was used, and the nominal “when new” size (10 to 20
Curies). Nothing is known of exactly when it was used; the best estimate
from testimony is late 1950s and possibly into the early 1960s before St.
Louis Testing Company entered the picture with their own Ir-192 and Co-
60 sources. Radioactive Ir-192 has a half-life 73.83 days. Therefore
knowing the exact Curies when the source was brand new, and the time
passed since use, are both critical for accurate modeling of this source.
None of those factors are known for the GSI owned Ir-192 source or for
the St. Louis Testing Ir-192 source for that matter. To my knowledge, the
St. Louis Testing Company Ir-192 and Co-60 source license was never
obtained and examined by NIOSH or by SC&A.

NIOSH has not modeled the two GSI portable 250 KVP x-ray
machines correctly. No doses to these sources were assigned in the
Allen NIOSH August 2011 Path Forward white paper on portable GSI
sources. NIOSH knows practically nothing of where the units were used,
what they were used for (what were the NDT inspection targets, how
frequently were they used, and by what workers. What were the exposure
conditions (dose rate, time). These units were not equipped with safety
interlocks. OCAS-IG-003 mandates doses from these sources must be
determined.

This is an SEC Issue because NIOSH has not demonstrated it can
model these two sources with sufficient accuracy.

The petitioners challenge the NIOSH dose model for the two small
(nominally 500 mCi) Co-60 sources used in the 6 Building
Radiography building at GSI. These data are based on NCC measured
data from 1962 during and before the date (June/July 1962) that
indicated was when added steel plate and concrete shielding was added

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Dragon, Karen E. (CDC/NIOSHIEID) x

From: DanMcKeel2@aol.com

Sent: Monday, May 21, 2012 4:25 PM

To: NIOSH Docket Office (CDC)

Ce: danmckeel2@aol.com

Subject: Docket 140 GSI: PETITIONER DOCUMENTS 3-8
Attachments: McKeel_ADD3.pdf+.zip

Dear NIOSH Docket 140 (GSI) Office:

Attachment: DOCUMENT 3: <McKeel_ADD3.pdf> (288 KB)
Attachment: DOCUMENT 4: <MCNPx_memo_3.22.12.pdf> (73 KB)
Attachment: DOCUMENT 5: <McKeel_Comment_Allen2_ADFD3.pdf> (477 KB)
Attachment: DOCUMENT 6: <McKeel_Part2_Allen_ADD-3.pdf> (411 KB)

—» Attachment: DOCUMENT 7: <McKeel_Comment_3.28.12.pdf> (76 KB)
Attachment: DOCUMENT 8: <DWM_GSI_email_Katz_4.26.12.pdf> (36 KB)

Please accept this submission to GSI Docket 140 for posting on the DCAS website. There are 6 small PDF files
representing 6 separate communications from myself to the TBD-6000 work group and full Board

Descriptions:
MCKEEL PETITIONER DOCUMENT 3. FILE: McKeel_ADD3.pdf (288 KB), dated March 19, 2012. Covers unresolved

SC&A "SEC Issues" 5 and 6 as well as more realistic and time period-accurate surrogate concrete induced radioisotope
activation data by the GS/ Betatrons.

MCKEEL PETITIONER DOCUMENT 4. FILE: MCNPx_memo_3.22.12.pdf (76 KB); McKeel Email dated 3/22/12 to Ted
Katz to distribute to TBD-6000 work group, DCAS and SC&A containing John Ramspott information about MCNPx with
Dan McKeel comments.

MCKEEL PETITIONER DOCUMENT 5. FILE: McKeel_Comment_Allen2_ADFD3.pdf (480 KB) dated 3/23/12. 2 page
initial reaction to mistaken calculations in David Allen's Addendum 3 action items white paper following the 3/15/12 TBD-
6000 work group meeting.

MCKEEL PETITIONER DOCUMENT 6. FILE: McKeel_Part2_Allen_ADD-3.pdf (411 KB) dated 3/26/12. A critically
important document showing that layout worker photon and neutron external radiation doses should be increased based
on new knowledge they worked immediately outside the GSI new Betatron shooting room shielded only by a thin steel
ribbon door that offered scant protection to them.

MCKEEL PETITIONER DOCUMENT 7. FILE: McKeel_Comment_3.28.12.pdf (80 KB) dated 3/28/12. McKeel read into
the record of the 3.28.12 TBD-6000 work group meeting. Very important rebuttal to the DCAS and SC&A presentations at
the same meeting.

MCKEEL PETITIONER DOCUMENT 8: FILE (PDF of email): DWM_GSI_email_Katz_4.26.12.pdf (40 KB) dated 4/26/12.
McKee! added comments about the TBD-6000 work group 2 Yes (Ziemer, Munn), 1 No (Josie Beach, 1st ten years of
covered period) recommendation on 3/28/12 to support NIOSH and to deny the GSI SEC-00105 petition for the entire
covered period of 1953-June 1966.

Sincerely,
-- Dan McKeel May 21, 2012

Daniel W. McKeel, Jr., MD
GSI SEC-00105 co-petitioner
Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com
US Mail: P.O. Box 15, Van Buren, MO 63965-0015



McKeel Comments 3/28/12 TBD-6000 work group meeting

to the Building 6 radiography facility. One set of NCC measurements,
according to NRC FOIA 2010-0012 documents, was obtained in January
4962 before the shielding was added and the other set were made during
the period the extra shielding was being installed. The petitioner offered
an analysis of the geometry of the Building 6 overhead crane and catwalk
which suggests it might have blocked some of the C0-60 source radiation
from below, The accuracy of the NCC Bldg 6 Radiography facility
measured data was not checked using MCNPx, which seems to the
Petitioner to be an obvious thing to do. (a) the NCC data accuracy could
be established on a firmer scientific basis, and (b) the NCC measured
data could serve to validate the MCNPx model.

This is an SEC Issue: NIOSH cannot assign doses from the small

0.5 Curie CO-60 sources because complete information is not known how
these sources were used and because workers testify that some of the
enumerated safety procedures the GSI 1962 AEC license application

stated to be in place were not followed according to worker testimony.

-- end--



McKeel Comments 3/28/12 TBD-6000 work group meeting

McKeel Petitioner Comments on NIOSH Allen August 2011 and January 2012
Path Forward For GSI White Papers and Addenda to Them
A general comment is that my time to present today is limited and the work group
has an extensive agenda. Although these remarks focus on the two Allen NIOSH Path
Forward white papers, | raise SEC Issues as well to save time.

A. Regarding Allen Addendum 3:

1. McKeel agrees with SC&A that the New Betatron model is still not correct:

(a) The modeled New Betatron tunnel door was NOT double leaf
minus lead shielding. It was a thinner ribbon steel roll up door, the exact
physical characteristics of which, including the thickness and type of steel,
are not known. There was no lead shield. Petitioner 3/15 data was
ignored.

(b) Allen did not model badge position 2 for the GSI New
Betatron film badge rack when it was moved farther away from the
Betatron source during 1964-66. Again, petitioner 3/15 data was ignored.

(c) The GSI-Landauer program 2084 film badge data has not been
analyzed thoroughly and accurately, nor has it been presented in entirety
to the TBD-6000 work group or the Petitioner. McKeel’s most recent white
paper to the Board on 3/27/12 showed evidence of a exposure of 300
mrem that newly appeared on a worker record between 4/25 and 5/29/66
of the covered period. McKeel interprets this as a previously unreported
overexposure incident that was apparent from a detailed temporal analysis
of film badge records that NIOSH has possessed for several years. The
replicated record showed 33 records on one page. There were 21
instances of Cumulative photon dose “M” and 12 instances of photon
doses ranging between 10 and 2470 mrem with several 20 mrem and a 40
mrem dose. No sheets had any beta or neutron doses recorded.

(d) McKeel introduced a new real world New Betatron Layout

worker shooting scenario attested to by former GSI Betatron employees

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McKeel Comments 3/28/12 TBD-6000 work group meeting

and contained in one of his four recent communications to the TBD-6000
work group following the 3/15/12 work group meeting. That is, layout men
worked on castings that required a quick turnaround—“hot,” rushed or
urgent NDT jobs—in the rail tunnel just outside of the thin roll up steel

door while shooting was ongoing. Two workers who are known to the work

group and SC8&A offered this new affidavit information.

The SEC issue regarding GSI film badges is the pedigree of
these data:

(a) Limited to males (one gender),

(b ) Limited to one job class (Betatron employees) that itself is
heterogeneous including clerks and photography technicians),

(c) Available for only 3 years (1964-66) out of a 13 year covered
period,

(d) No measurements of beta dose or neutrons;

(e) Available on only 89 individuals out of a work force of 3000 to
4000 persons.

There is no reasonable scientific basis to construe these very
limited badge data as being representative of the work force. Nor should
they be extrapolated to cover all workers during the entire 13 year covered
period of 1953-1966.

These very limited film badge data are not even bounding for
Betatron employees who wore them only part time. Badges were not
worn, for example, by Betatron employees doing layout in the New
Betatron tunnel on urgent “hot” or rushed casting jobs. Those unbadged
layout employees would be expected to have the highest exposures of

any employees. These doses have not yet been modeled by NIOSH or
SC&A during the Path Forward time period from October 2010 until today.

2. Petitioner challenges the validation of a 25 Mev New Betatron source
using a post-1968 GSI cobalt-60 source (54 not 80 curies, beam geometry
very different, Co-60 source does not model neutrons that were 15% of

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